License No. SDGT-2016-329575-1

Date issued: Jul. 16 2016

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TURBOFAC Commentary (323 words)

Notes:

1) The Licensee here is a formerly blocked (SDGT) U.S. person entity that had, from the time of its 2004 designation (https://home.treasury.gov/news/press-releases/js1895) through the 2016 dissolution of the entity (see p. 2, PDF), been a defendant in U.S. litigation relating to terrorism. This is a rare unblocking license in that the context is an agreement with OFAC whereby the entity would be delisted, and where “OFAC required that the organization be formally dissolved and that its remaining (limited) assets be distributed” (see p. 3, PDF). This license authorizes (i) the dissolution of the entity (which would otherwise be prohibited), (ii) the making of payments to four law firms to satisfy an order by a federal court for the payment of attorneys fees in connection with discovery sanctions (see p. 7 et seq., pdf), (iii) payment to Al Haramain’s counsel out of remaining funds,...